At SFS Capital, we understand the importance of protecting an individual’s right to privacy. In the course of providing a service to you as an individual or corporate client, we may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we are also committed to safeguarding the privacy of your information while complying with the provisions of Nigeria Data Protection Act of 2023 and other relevant regulations at all times.
This Privacy Policy describes our treatment of your personal information on all our platforms and is designed to help you understand how we may process any personal information obtained from you.
By providing your personal information to us, you have signified your acceptance of our Privacy Policy and agree that we may collect, use and disclose your personal information for specified purposes as described in this Privacy Policy.
The kinds of personal information that we collect will vary depending on the type of dealings we have with you and how you interact with us. Generally, we may process the following information:
1. Personal Identification Information – Where you invest in a fund or other products of SFS Capital, make payments for our products and services, respond to a survey, or fill out a form, we will request for your demographic information, email address, telephone number, occupation and any other information we may deem necessary.
2. Statistical Information – We may collect statistical information relating to your use of our website or other online services, including your server address, the pages you accessed, and documents downloaded, the type of browser you are using, technical information about your means of connection to our Site, such as the operating system and the internet service providers utilized. We will not normally be able to identify you from such statistical information.
We may also collect personal data in the following ways:
Information from our social media sites: We may collect information through your engagement with us on our social media sites (Facebook, Instagram, LinkedIn, Twitter). This includes your replies to our posts, your comments, enquiries and support messages. However, we will only ask for information required to help us be of service to you
Third Parties: We may also receive your information from third parties such as financial institutions and service providers.
Job Application: When you apply for a job with us, we will request Personal Data about your education and employment history. As part of your application, you will be asked to provide your express consent to our use of this information to assess your application and any monitoring activities which may be required of us under applicable laws as an employer.
We may also carry out screening checks (reference, background and criminal record checks).
We may exchange your Personal Data with academic institutions, recruiters, health maintenance organisations, law enforcement agencies, referees and your previous employers.
Without your Personal Data, we may not be able to process your application for positions with us.
We do not collect information of minors.
SFS Capital collects your personal information in order to facilitate and manage our relationship with you. Specifically, we collect personal data for the following purposes:
We do not sell or market your personal information or personalised data to third parties.
Typically, we receive personal data directly from Data Subjects. We may also receive personal data from third parties. The following are methods through which we collect personal information: Direct collection:
Third party’s data collection source:
Cookies are small files placed on your device’s browser that enables the website to identify your device as you view different pages. We use cookies to track browsing history of visitors to improve their experience.
We retain Personal Data for 10 years after your relationship with us has ended in order to fulfil the relevant purposes set out in this policy and to comply with our legal and regulatory obligations. We may retain Personal Data for longer periods if it is in our legitimate business interests and required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.
We may share your Personal Data or other information about you with others for the following reasons:
With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, verify your identity or provide customer support.
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including:
With your consent: We also will share your Personal Data and other information with your consent.
All of your personal information is stored in a secure environment, where electronic and procedural safeguards have been put in place to mitigate against loss, misuse, damage or unauthorized access. We also limit access to your personal information to authorized employees.
I. Requests to Access, Rectify or Erase
You have the right to ask us whether we hold any Personal Data relating to you and, if we do, to be provided with a copy of that Personal Data in electronic form, unless you want to receive it in another way (for example, a paper copy). In addition, you can ask us for information on how we use your Personal Data, who we share it with, how long we keep it, where it is stored, and other information to help you understand how we use it.
You have the right to ask us to correct your Personal Data if it is inaccurate and to have incomplete Personal Data updated without undue delay. If we cannot correct the Personal Data, we include a note on our files regarding your request to correct your Personal Data.
You have the right to ask us to erase your Personal Data if:
In these cases, we can restrict the processing instead of erasing your Personal Data if requested to do so by you.
II. Requests to Object
You have the right to object at any time to the processing of your Personal Data if we process it based on our legitimate interests. This includes any so-called “profiling”. Our privacy notice informs you when we rely on legitimate interests to process your Personal Data. In these cases, we will stop processing your Personal Data unless we can demonstrate compelling legitimate reasons for continuing the processing. We may reject your request if the processing of your Personal Data is needed to establish, exercise or defend legal claims.
III. Requests to Restrict
You have the right to ask us to restrict the processing of your Personal Data if:
If processing is restricted, we may process your Personal Data (except for storage purposes), only:
IV. Requests for Portability
You have the right to ask that we transfer any personal information that you have provided to us to another third party. Once transferred, the other party will be responsible for safeguarding such personal information.
Even if you request the portability of your Personal Data, you retain your right to also request their erasure.
V. Requests to Object to Automated Decisions
Generally, you have the right to object to any decision producing a legal effect concerning you or which otherwise significantly affects you if this is based solely on the automated processing of your Personal Data. This includes automated decisions based on profiling.
We may refuse your request if the decision in question is:
We will only make decisions relying solely on automated processing that involve your sensitive Personal Data if you have given your explicit consent or the processing is necessary for reasons of substantial public interest, based on the NDPR and relevant laws.
All of your personal information is stored in a secure environment, where electronic and procedural safeguards have been put in place to mitigate against loss, misuse, damage or unauthorized access. The security measures include firewalls, physical access controls to our premises, CCTV cameras for public safety and quality control as well as information access authorisation controls. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
We will inform you of any breaches which may affect your Personal Data.
In the event of violation of this policy, our Data Protection Officer shall within 7 days redress the violation. Where the violation pertains to the disclosure of your Personal Data without your consent, such information shall be retracted immediately, and confirmation of the retraction sent to the you within 48 hours of the redress.
Our Privacy Policy may change from time to time. We will post any privacy policy changes on our website and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). Unless otherwise stated, the current version shall supersede and replace all previous versions of this Policy.
You acknowledge and agree that it is Your responsibility to review this Policy periodically and become aware of modifications.
If you have any general questions or concerns about this Privacy Policy or the way in which we handle your Personal Data, kindly contact us via the details below:
SFS CAPITAL NIGERIA LIMITED
287 Ajose Adeogun Street
Victoria Island, Lagos
Email: (help@sfsfund.com)
Phone Number: (+234 708 961 9093)